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JOSE ARTURO RODRIGUEZ, SBN 116541Attorney at Law84426 N Sienna CircleCoachella, CA 92235Tel: 760-698-8792arodriguez2 @dc.rr.com

FILED

S~Kt~ ~ cot~ tt]:6~RK’S orFlC~

LOS hNG~S

In Pro Per

STATE BAR COURT

HEARING DEPARTMENT - LOS ANGELES

In the matter of

JOSE ARTURO RODRIGUEZ

SBN 116541,

A Member of the State Bar.

CASE NO. 15-0-13425

RESPONDENT’S ANSWER TO NOTICE

OF DISCIPLINARY CHARGES

Jose Arturo Rodriguez responds as follows to the Notice of Disciplinary Charges filed

March 28, 2016 in the above-referenced matter:

JURISDICTION

1. I admit that I have been a member of the State Bar of California in good standing frorr

my admission to the bar on December 28, 1984 and until the present and that the State Bar b_~

jurisdiction over this matter.

kwiktag ® 211 096 852

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COUNT ONE

Case No. 15-013425

Business and Professions Code Section 6103

[Failure to Obey a Court Order]

Respondent disobeyed or violated an order to the court requiring respondent to do,

or forbear, an act connected with or in the course of respondent’s profession, whic~

respondent ought in good faith do or forbear, by failing to comply with the court’s minute

order dated April 15, 2014, which required that respondent pay a sanction of $3000 in the

case entitled Javier Miramontes, et ai. v. California Rural Legal Assistance, Inc., et aL,

Riverside County Superior Court No. INC 1302881, in willful violation of Business and

Professions Code, Section 6103.

Response: I admit that I have not paid the sanctions issued on April 15, 2014 in the

above-referenced matter. I deny that the failure to pay the sanctions has been willful. I am

disabled under both state and federal law and have no source of income with which to pay the

sanctions. My only source of income, since 2013, has been Social Security Disability Benefits

in the amount of $2049.00 per month. My monthly mortgage payment is $1042.00 which leaves

me with about $1000.00 per month to meet all of my other needs.

However, I also believe that the sanctions imposed were not supported by the facts and

law of the case and were obtained on tainted evidence, i.e., a heavily "redacted letter" in which

six entire pages of the seven pages were "redacted" completely, leaving a false impression thai

the letter was sent for an unlawful purpose. The judge who issued the sanctions, Hon. David M.

Chapman, refused to admit the full seven page letter into evidence and refused to even review i!

before making the decision to issue the sanctions on the basis of the redacted letter only.

The redacted letter and the original letter, with exhibits, are attached hereto as Exhibits

and 2, respectively and incorporated by reference, as if fully set forth herewith.

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COUNT TWO

CASE NO. 15-0-13425

Business and Professions Code section 6068(0)(3)

[Failure to Report Judicial Sanctions]

Respondent failed to report to the agency charged with attorney discipline,

writing, within 30 days of the time respondent had knowledge of the imposition of judicial

sanctions against respondent by failing to report to the State Bar the S3000 in sanctions the

court imposed on respondent on April 15, 2014/n connection with Javier Miramontes, et

v. California Rural Legal Assistance, Inc., et a£, Riverside County Superior Court No. INC

1302881, in willful violation of Business and Professions Code, Section 6068(0)(3).

I admit that I failed to report the sanctions in a timely manner as required by sectior

6068(0)(3). I was not aware of the reporting requirement as I have never been sanctioned in m’

31 year legal career, with this one exception. In mitigation, I immediately filed the necessar

report once the matter was brought to my attention by the State Bar on August 14, 2014.

However, I believe that the sanctions imposed were without factual or legal support an,

thus, should never have been granted.

Respectfully submitted this 10~ day of May 2016 at Coachella, California.

Jose ~/~~ez, S\ ~.__~ BN 116541

11184426 N. Siemm Cb’deCsaehdla, CA 9223~

Tel~ 760-69~8792Cell: 760-23~2966

January 15, 2014VIA ELECTR(E~C TRANSMISSION AND US MAIL

Ms. Jennifer K. SaundersMs. Blythe L. GolayHaight Brown & Bonesteet, LLP555 South Flower Street, Forty-Fifkh FloorLos Angeles, CA 90071

Miramontes, et al. v. CRLA~ 1~.;, et al.Riverside County Case 1"4o. 1302-881

Dear Ms. Saunders and Ms. Golay:

Ms, Saunders and Ms. Gohy as you are aware, at the most xecent hearing on December 20,2013, the Honorable David MI Chapman sustained your demurrer and.m0tion to strike subject tothirty (30) days leave to amend. By oureakulations, the Third Amended-Complaint (TAC) is dueto be filed no later than January21, 20t4(th~ 20~:of hnuaty. ~ on ~ Luther King day, acourt holiday.) Before eallLrtg the d~s la~ and m~tio~ ~ ~ day, Judge Chapmmaintroduced one of the newest Riverside County Superior Court judges recently appointed byGovernor Brown, Superior Court Judge Sunshine Sykes.

Coun~l, your defense of this ease ispartly ~,on ~e following mgament which youmade to the Court in your demurrer to the-Se¢o~ Amended.C0mplaint (SAC).

"TakingP " " ’ .....lainfiffs Complaint to its eore, the allegations are ~ more than the personalvendetta of Mr. Rodriguez to retaliate against his former employer, CRLA, at~ he wasterminated for, among other things, ~ ~ferbally and i~hysiealty abusive to other CRLAattorneys and employees. (See Workplace V "mlenese.R~ Order, filed August 2, 2012,attached as Exht\bit "B" to Request to take Jugh\eial Nonce. It is also important to note thatdefendant, Megan Beama~ is one 9fthe Protected PerSons under said Order." (Demurrerto Plaintiffs’ Complainlg page Ifl~. 8-13.)

First, as I have already argued m the Court in our opposRion briefs, the TRO which CRLAobtained, was filed in June of 2012 andthe injamctionissued on ~A~West 2s 2012. The Miramontes

P~e r of 7

Letter to JenniferBlythe L. GolayJanuary 15, 2014

v. CR/~ action is based on tim evenls:that trafispircd from. March 27, 2012, when CRLA waspresented with the Substitution of Attoracys forms, thrOt~ ~ 21, 2012 when the Com’t deniedCRLA’s unauthorized motion and ordered the filing ofthe~ S~ons which hadserved on CRLA two months earlier. Th¢ TRO has absolutvbyno rdcvance to the events of March27, 2012 through May 21, 20tZ

Counsel, in your rcque~ for-J~ No¢i¢� fd~d 0ol~ar~nt!y with your demurrer andmotion to strike the FAC, youattadacd as.Exhibit "W’ Wo.d~ace Vi01enceRe ~rainin: g Order whichCRLA includext a declaration from Megan_ Bcaman in support of~e Order. tn her dcc!aration, Ms.Beaman makes ~the follows a~c:ms tinder penalty of pcrju~:

"Axturo showed up a few days tater at a status conference in Riverside in our case US. v.Harvey Duro, while on ~ve leave, de~mC~RLA’ ~r~ion to him that he notappear. During the ~ and at counsel’s table Artu~ passed m¢a slaff profile ofSunshine Sykes at the counset~ ~ $~.kr ~m/a~ a,~_k who l :kave kadpersonal issues- with for ~y~ and~ l~ tl~~ me m tke p~st. ArV~ Isawar~ of the issues I have with"h¢~ and fiscd tl~ ~n to.aggravate m¢ during thehearing. [Emphasis Added.] ms declaration was signed on June 21~, 2012.)

Approximately a year earlier on June 29, 2011,.M¢$~ sent,two emails toall of the Coachellaoffice staff and to o~ Suporvising Attorney, Michol ~-~ then Riverside CountyDeputy Counsel Sunshine ~ The ~s sta~ as follows:

The first email read as. follows:

"[M.zu" Friends, I want to let you know that I have asort of stalker that. has ~ a 10t ofthings including to call or visit my office in an �ffoct to "dcstro~ me. She has alsothreatened to call JoseJ She is Mario~s.ex. Idon’~ lmowwhatshe th/nks she can accomplishby calling CRLA as I !have n~~hide so ~.~um¢ she,might make up lies about me. Iam tetting all of you even ~ it is:personal and em~g because she has escalatedher threats lately andI’m not ~ what sl~ might-be~!ofldohlg.- Of course, ffshedoes do something I will do wtmtIcaa to.get are~ ord6r. But in the meantime, mease she ealls or visits the office, I!just warn you to.lmow~what~$ going on, Also like always

I

The reference m Jose, is to Jose Padilta, CRLA’s Exeolltiv¢ ~.

Page 2 of 7

Le~er to Jenner K_ Saunde~B~the I~ GolayJan#m~ 15, 2014

just tell callers I am "unavail~le." I am working from home today for this reason. Mike or ~Art~roif there are ~fiarther steps t shoutdtake now;please let me kn~w., itdo~’t care who I necxt to call; I .amnot protecting her identity, ete aaymor~ and just want to tn’~cnt ammyanee to CRLA if possible.Sorry for the hassle everyone."

The second email wad as fotlce#s:

"PS her nameis Sunshine Sykes,~~ tiesm~t,saysS~Marfinez, SheisalsoRiverside County Deputy Counsd (~r~ tl~ t~1/~y are ~). I don’t know whattype of shenanigans -to expe~ bnt may ¢~ts or aa~thing ~ happens please let me know.Thank you everyone for undetsl~ding." (Copicsof~two eanails are attached as ExhibitA to this correspondence,)

MEGAN BEAMAN

Megan came to work for,CRLA in September 0£2008 as a staff attorney in our Coache}|aOffice and was subsequently admitted to the:~mia.State ba~..~in orabout D~.~mber of 2008afterpassing the-California Smt¢ Ba~ e~.am~ At the time that lvtega~: ~ with CRLA, she had beenmarried to her college sweethe~who moved with her to Calif~a ~om Wisconsin to allow.Meganto work for CRLA. During her first yeatofempto~-Meg~,w~s a dedicated, ~compe~nt,- hardworking and appeared to have dedieal~,~.herself to ~ tx~siti~ as a CRLA staff attorney. Meganhad been my first choice from amo~lg ~ applieaniswho.had~l~ti~l to fiBthe Coaehellastaffattorney position and my initial "map~ssiou of M~ _l~n was tha~she was ex~|y briglrt~ serf-assured and teeming with self, eonfi~: spoke St~!aisi~ ~:ia my opinion, had as’mueh or morepromise than the majority of attoraeys with when [ had ~~ in the Coachella oftiee,

In late August or early Se~~2010, ~ ¢am~ to my office .in the morning. Meganwas visuatly upset and crying. ~ had Come to ,telI me the,she had ~ a "horrible-mistake,"that she had "fallen in love" with her eo-~tmsel .M~o ~ and had been havktg an ~ withMr. Martinez. Mario Martinez was a l~ivat¢ aRomey who ~ eo-eotmseling with Megan on herfirst federal case, EEOC v. Giumarra. M~;n wca~ ¢m ,~ly tliat: Mr, ~’ t~lr~ SuasKmgSykes, had found out about the affair amli!ad to!dMeg~ ~ ~ Ms. Sykes intended to call me andour Executive Director., Jose Padflla, to ~ain about the ~ashipand that Ms. Sykes "wasoutto destroy her". Megan.-, also ~ that-Ms. Syke~ was nOt taudly married to Mario ~z butnonetheless referred to herself as his ’~ife", ttmt Ms: Sykes_ had emotional issues and refused toaccept the fact that her relationship with Mario ~ was over, that Ms. Sykes-’had been"stalldng" Megan and had repeatc~Ythteaten~l~to ~~ Mc~ma admitt~that she..hndmade a "horrible" mistake by havingbad the~ with Mario ~ and that she was afrrAd’that

Page 3 of 7

Letter to JennOrer K. SaundersBlythe Z. Go~ayJanuary 15, 201’4

disclosure of her relationship to Mario Marti__nez would, ruin her career with CRLA. She also toldme to expect a call from attorney Mario Martinez~ ! did in fact receive a call from Mr. M~z laterthat day during which he admitted that_the affair ~had been a~ble" mistake and that he andMegan would understand ifI removed Megan~from th~ Ghanan’a mat~. Both Megan and MarioMartinez asked meto leave Megan onthe ease and thattheaffair was"over" and that it would never

Shortly after my telephonic eonversaiion with Mario~ Mar~ez, I received a eatt fromSunshine Sykes. Unfortunately, I was. ~aot in the office when the call came inand Ms, Sykes left adetailed message eonfira’hng that she had.discovered that her husband Mario Martinez had beenhaving an affair with Megan and that she thoeght it was higlaly !mprofessional and that I should, ata minimum, remove Megan ~om the ease~ She also stated in ~ message that she ~had intended orhad already catied our central office in Sa~l Francisco-to speak withCRLA exeeut/ve ~rector JosePadilla,2

I did not return Ms. Syl~s~e call for the following reason~ First, Megan, Mr.Martinez and Ms. Sykes had all c, onfirmed~ the.existence ofthc~affair. Second, Megan .begged menot to puIt ~her from the.case and to not bring the matter to-.the atlgnfion of CRLA Executive DirectorJose Paditla or other senior CRLA ~magcment. And of coarse that the affair had been a horriblemistake and she did not want her hu~,a~d to find out as she didnot want a divorce or separation.

As;there was no dislrate that the ~ had happened, ! ~that ! did not need any furtherinformation from Ms. Sykes. The �’~ facts hadborn ~lished,-both Megan and MafioMaaJnez each gave me their assurance that the short, term affair was o~er and each wanted tocontinue to work on theGitu-narra ease~ Las~y, I consider~-thefaet that Ms. Sykes was aware ofMegan and Mr. Martin" ez’ relationship and that she had-demomtmted that she would have noproblem informing me and/or CPd~A ffthe relationship wcam to resurae in the future. After muchinternal debate as to what t should do at this point, Imadeth¢ decision to rely. on and accept Meganand promises, as attorneys and Officers 0f the Court, that the rC!ationship was overand informedthem after some de[ibexation*d~t I wou~ not remove Mcgan from-theea~~. unless I was directed todo so from senior management. I.take respamibiti~ for this decision and received noemmmunication from CRLA maaagem~nt~ this issue.

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I did ,not h~’ar from.Mr., Paditla oF any otber CRLA selaior nmnag¢, r and do not know if the. ~messag¢was received or if it had and been dismissed by Mr. Padilta or some other CRLA senior manag~;

Page 4 of 7

Letter to Jenn~f~,r K. ~gaundersBlythe L. GotayJanuary 15, 2014

In hilldsight, I now know th~ t ~ m~e a lgli~eby, lnot retUl"fling Ms. Sykes telephoneealt. Let me explain. When Megan ~ her "confession" aboat her affakwith Mr. Mar~ez, sherepresented the following ’Yaets" in part toexplain why the al~dr had happened. First, Megan toldme that Sunshine Sykes was ’haot really married" toMr. Martinez and portrayed Ms. Sykes as MarioMartinez’ "ex girlfriend" who sometimesreferredtohersdfand Mario ~z’ wife. She impliedthat the affair had been short lived and that Ms, Sykes had only rece~y found out about therelationship and had gone ballistic spawniag the slew of~and intimidating actions .- Megandid not mention or in any way imply that-Ms, Sykes, and, I~, ~ had chiidren together.Instead, Ms. Sykes was poruayed by Megatias aformer. - ’~gir!fiiead" ofMr. Martdaez’ who just couldnot aeeept that .her relationship ~had endedand that she woatd ~ "anything to "win Mr. MartinczbacL"

Approximately one year after tl~ initial disolosures Of the affair by Megan and MarioMartinez and Ms. Sykes, I had begun to susp¢~ that Meganaad:MarioMartinez’ relationship hador was regressing. My suspicions pro’,~d correct when t was informed by our supetvifmg attorney,Michael Meuter, that he wottld be coming to Coaehelta (Mr. Mcuter is based in our Satinas office)to meet with Megan, Mario Martinez a~-several attom~s from the federal Equal EmploymentOpportunity Commission (EEOC), CRL~ A’s eo,c, omm¢l in ~ Oiummara ease. Tire meeting,according to Mr. Meuter, was to discuss and attempt to resolve what Mr. Meuter described as "astrained relationship" with the EEOC aRon~ys and M~gan ~,Mario Martinez.

The meeting, to my reoollectio~.tasted a fi~l day. Duringa break I co~. Megan andasked her if she and Mario Martinez had ~esumed thegr "relationship." Megan, .smiled and said yesand added that she and Mr, Martinez ~ taking it slow," t told Megan that it was unaeeeptableto me and that I would have to disclose her relationship to CRLA senior mmmgement beginning withour immediate supervisor, Michael. Meuter and that I intended to recommend that she beimmediately relieved of her responsib’~ onG~umarra; Megan smiled and totd me that she hadalready informed Mr. Meuter about her relationship with Mario, Martinez and that Mr. Meuter hadtold her that he did not have a problem with it and that she would be allowed to remain,on theGiumarra matter. Mr. Meuter wasin our Coachella office that ~day and I asked to speak with himin the privacy of my office during a later break. I asked Mr, Meuter if it was-true that Megan hadinformed him abou~ her affair with Mario. Martincz and that he had authorized her to eont’mu¢working on the case. Mr. Meuter acknowleatged that Megan had informed him about her relationshipwith Mario Martinezand that he did not s¢� any problem.with them continuing to work together onthe case. I told Mr,. Meuter in no uncertain-terms that he was ~ a huge mistake. Both Meganand Mr. Martinez had lied to me a year earlier when each expressed remorse and each promised thatthe short-lived affair was over each of them admitting that R hail been a huge mistake, t told Mr.Meuter that as far I as I was eonocme, d I had~lfill~d my obti~ationsan ttm Dir~ting Attorney of theCoachetla office and that Mr. Meater was responsible to any eonse~enees.

Page 5 of 7

Letter to Jen~fer K~ SaundersB~he L. GolayJanuary 15, 2014

Unfortunalely, I did not illitia~ ¢.olitagt with. S~Sykes ulltil after I had bgen terminatedby CRLA on March 1, 20t2. Shortly aRcr my ~ I initiated contact with Ms. Sykes andspoke with her in a series of telephone conversations and in a meeting in RiversAd¢. Ms. Sykesprovided information which ¢onmatietcd Megan’s ~ :~tations to me about thecircumstances of the affair. First, Ms. Sykes confirmed that she and Mario Martinez were in factlegally married. Fta~hermore, she and Mx. Martinez hadthr~ daugtaers together, and that she hadbeen pregnant with their fourth child (another daughter) during the ~ timt the affair had bgenongoing. Ms. Sykes had learned of the ~ from Mario ~’ ’~tivat¢" emalt cortt, spondencewith Megan which Ms. Sykes had managed to access a~or having suspicions, that the relationshipbetween Megan and her husband was mox¢ than a p~fcssicamllworl~g relationship. Ms. Sykesstated that the affair, as far as she couldtell, had begun as early as February of 20i0 and had beenongoing tmfil Ms. Sykes discovery 0fth¢ ~ in late August or early Septeanber of 20t0, a periodof 7 to 8 months after she believed it ha~:slarted. Over the course of our conversations, Ms. Sykesprovided additional/xfformation which I Witl not discuss at this point but which highlightedMegan’sinconsistencies with the story that.she had/nitially :told m¢ abom the affair.

I had provided some of this information.to~ my former CRLA colleagues aflerI had beenterminated by CRLA (and before the filing of this Ii~tigation) ~th the hope that they woukl conductan investigation of Megan’s odd and highly uaprofessionat ~onduct, particularly as it related to.herhighly inappropriate relationship with Mario Martinoz and the defama~ry lies and omissiom thatMegan had sprouted and decimated about Ms. Sykes within CRLA to "justif3," h~r affair with MarioMartinez. None of my pleas were acted upon.

Counsel, I have endeavored to include enough ~ve facts in the First and SecondAmended complaints to survive your demun, ers and motions to strike without providing all oftheinformation discussed in this correstxmdenee. At this poi_a~ Iha~ an obligation.to my clients to addsome of the facts discussed in this correspondence in an attempt to save the causes of action forBreach of Fiduciary Duties, Intentional Infliction of Emotional Distress and Interference withProspective Economic Advantage. lg given no alternative, t ~ file the TAC on January 21, 2014.

I have practiced law almost exclusiv©ly in Rb~’rside Coumy grace I moved.to the Coach¢llaValley in 19.87 to begin my employment wth- CRLA. As an attorney, my duties tomy clients dictatethat I bring some of these facts to the att¢ntion of ~e:Court in ~der.to survive the next demtLrrer andmotions to strike the TAC. However, I am also an Officer of the Court and have a professionalobligation not to bring disrespect to tbe-Coun. Also, Ihave the utmost respect for Jttdgc Sutlsbi-rlcSykes. Press accounts of Ms. Sykes appointment to the Riverside County bench have emphasizedMs. Sykes background. Judge Sykes is a graduate of Stanford Univ~’sity and of Stanford taw

Page 6 of 7

Lette~ to J~nnif~r K. SaundersB~h~ I.~ G~layJanuary 15, 20~4

school. She is a Native American ~(Nav~o) and is the first Native American appointed as a judgein Riverside County. During my conversations with Ms. Sykes before her appointmem to the bench,I was highly impressed by her professionalism, by her accomplishments as a Riverside DgputyCounty Counsel and, equally, as a re_other of four young daughters. I have no desire to bring anynegative publicity for Judge Sykes and am looking forw~d to her hav~ng a long productive careeras a Superior Court Judge.

Counsel, we are requesting a 30 day extension, to.and including February 1, 2.014, by wayof stipulation before filing the TAC. We intend to.,se~d courtesy copies of this correspondence tothe Board of Directors of CRLA to suggest that we-meet, at the earliest possible date, to discusssettlement options. We would insist that at t~ast one Board.representative, preferably an attorney,attend the settlement meeting.

Please reply to this correspondence ~t your earliest ~ty. ffwe cannot get the thrityday extension, we will only have three ~of action. The. first and least preferable option, to filethe TAC with added facts which we have outlined in this ~nce. The second choice,which we would much prefer, is to arrange asettlement mceting:(at your Los Angeles offices ffthatis your preference) on the soonest possible date after stipulating m the thirty day extension to file theTAC. Our third option, will he to file an ex parte al~lication to be heard by Judge Chapm ~an, JudgeSykes newest judicial colleague, request/rig that the Corot grant the thirty day extension to file theTAC and to request inlet and guidance from the Court.on howbest to proceed with this litigationwithom the risk of potential negative publicity which would undoahtediy do little.to adva~e thereputations of CRLA, Megan Beaman,~Micha¢l Meuter and ilen¢ JacobS, the def~tt~ants in thisaction. Of course, we would also expect that the negative Imbh’¢ity would also harm Judge Sykesreputation as well.

Counsel, please let us know if you are wilting to stiput~_e to ,the thirty day extension to filethe TAC and schedule a settlement mee "tmg, again with a least one Board representative, at theearliest possible opportunity. Time is ofthe essence, Ifw¢ earmot resolve this matter as quickly aspossible, you can either expect notice of.an ex parte laeari~ tohe held no later than next Tuesdayrequesting that the Court grant us the ~ day extension or that. we proceed to file the TAC nextTuesday incorporating some of the facts- ~ated in this correspondence.

Sincerely,

Attorney for Plaintiffs

Page 7 of 7

E~IBIT A

9£~6 VD~t~

January t5, 2014

Ms. Bly~h~ L.~ Brown & ~ LLP555 Sotnta Flov,~r Street, Forty-Fi~ ~Los Angd~,, CA 90071

Mirar~ntes, et at v. ~ Inc., ~t atRiverside Comay ~. 1302~i

~lof7

January 15. 2014

15, 2014

~4~f7

.la~tua~ 15, 201,~

~5of7

J~uary i.~, ~,014

P~I~ 6 of’7

TAC. Ore’third option, ~be to ~m~~t~~by~ ~ Judge

/.epmnfiom of CRLA, Mesan Be=n~ ~ ~ ~ ~ Jaool~ the ~ ~ ~

~ion as

Stucerely,

Attorney for P~

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Proof of Service by Mail

I, Carmen L. Rodriguez, declare that I am over the age of eighteen and not a party to this

action. My home address is 84311 Calendula Avenue, Coachella, CA 92236.

On May 24, 2016, I caused to be served a true and correct copy of the below listed

document(s) entitled:

Respondent’s Answer to Notice of Disciplinary Charges

Case No. 15-0-13425

by first class United States mail addressed as follows:

Sherrell N. McFarlaneDeputy Trial CounselState Bar of California845 S Figueroa StreetLos Angeles, CA 90017-2525

I deposited such documents in an envelope, postage prepaid, by depositing said envelope with

the United States Postal Service in Coachella, C~lifornia.

is true

I declare under penalty of perjury under Me laws of the State of California that the foregoing

and correct. Executed this 24t~ day of May 2016 at Coachella, California.